Clark v. Sweeney

P R E L I M I N A R Y P R I N T
Volume 607 U. S. Part 1
Pages 7–10
OFFICIAL REPORTS
OF
T H E S U P R E M E C O U R T
November 24, 2025
REBECCA A. WOMELDORF
reporter of decisions
Page Proof Pending Publication
N O T I C E : This preliminary print is subject to formal revision before
the bound volume is published. Users are requested to notify the Reporter
of Decisions, Supreme Court of the United States, Washington, D. C. 20543,
pio@supremecourt.gov, of any typographical or other formal errors.

Page Proof Pending Publication
OCTOBER
TERM, 2025
7
Syllabus
CLARK v. SWEENEY
on
petition for writ of certiorari to the united
states court of appeals for the fourth circuit
No. 25–52. Decided November 24, 2025
A Maryland jury found Jeremiah Sweeney guilty of second-degree murder
and other crimes. After those convictions were affrmed on direct ap-
peal, Sweeney sought postconviction relief in state court. Sweeney ar-
gued, among other things, that his trial counsel was ineffective under
Strickland v. Washington, 466 U. S. 668, 686, for failing to voir dire the
jury to ensure that one juror's unauthorized crime-scene visit had not
tainted the other jurors. The state court denied relief after a hearing.
Sweeney then petitioned for a writ of habeas corpus under 28 U. S. C.
§ 2254 in Federal District Court, again arguing that his trial counsel was
ineffective for not seeking to voir dire the entire jury. The District
Court denied relief, concluding that the state court's application of
Strickland was not objectively unreasonable. The Fourth Circuit re-
versed in an unpublished opinion and ordered a new trial. Instead of
addressing the ineffective-assistance claim that Sweeney asserted, the
Fourth Circuit held that Sweeney's trial had been marred by a “combi-
nation of extraordinary failures from juror to judge to attorney” that
deprived Sweeney of his right to be confronted with the witnesses
against him and to be tried by an impartial jury. App. to Pet. for Cert.
22a, 29a.
Held: The Fourth Circuit transgressed the party-presentation principle by
granting relief on a claim that Sweeney never asserted and that the
State never had a chance to address. “In our adversarial system of
adjudication, we follow the principle of party presentation.” United
States v. Sineneng-Smith, 590 U. S. 371, 375. The parties “ `frame the
issues for decision,' ” while the court serves as “ `neutral arbiter of mat-
ters the parties present.' ” Ibid. (quoting Greenlaw v. United States,
554 U. S. 237, 243). The Fourth Circuit's “radical transformation” of
Sweeney's simple ineffective-assistance claim “departed so drastically
from the principle of party presentation as to constitute an abuse of
discretion.” Sineneng-Smith, 590 U. S., at 380, 375. On remand, the
Fourth Circuit should analyze the ineffective-assistance claim that
Sweeney asserted. See Dunn v. Reeves, 594 U. S. 731, 739 (per
curiam).
Certiorari granted; reversed and remanded.

8 CLARK
v. SWEENEY
Per Curiam
Per Curiam.
A
Maryland jury found Jeremiah Sweeney guilty of second-
degree murder and several other crimes. Sweeney's convic-
tions were affrmed on appeal, and his bid for postconviction
relief in state court was unsuccessful. Sweeney sought ha-
beas relief in Federal District Court, and that court, too, de-
nied relief. But the Fourth Circuit reversed and ordered a
new trial, relying on a claim that Sweeney never asserted.
Because the Court of Appeals departed dramatically from
the principle of party presentation, we reverse.
I
According to the State's witnesses at trial, Jeremiah
Sweeney was arguing one night with neighbors about stolen
marijuana. He eventually opened fre, missing his intended
targets but killing a bystander who was about 75 yards away.
At issue during trial was whether Sweeney could have been
the shooter given his location and the angle of the bullet
wound.
After the State rested its case, Juror 4's curiosity got the
best of him, and he decided to check out the crime scene for
himself. Shortly after jury deliberations began, Juror 4 told
the jury about his visit, and the jury promptly reported his
visit to the court. The parties conferred and eventually
agreed that rather than declare a mistrial, the court would
dismiss Juror 4 and deliberations would proceed with 11 ju-
rors. Sweeney was convicted, and his convictions were af-
frmed on direct appeal.
Sweeney later fled a petition for postconviction relief in
state court. He argued, among other things, that his trial
counsel was ineffective under Strickland v. Washington, 466
U. S. 668, 686 (1984), for not seeking to voir dire the entire
jury to ensure that no other juror was tainted by Juror 4's
unauthorized crime-scene visit. The state court denied re-
lief after a hearing. With the help of appointed counsel,
Sweeney then petitioned for a writ of habeas corpus under 28
Page Proof Pending Publication

Cite
as: 607 U. S. 7 (2025)
9
Per Curiam
U. S. C. § 2254 in Federal District Court. As in state court,
Sweeney
argued that his trial counsel was ineffective for not
seeking to voir dire the entire jury. The District Court de-
nied Sweeney's petition, concluding that the state court's ap-
plication of Strickland was not objectively unreasonable.
In an unpublished opinion, the Fourth Circuit reversed—
but not on the ineffective-assistance claim that Sweeney
brought. Instead, the Fourth Circuit declared that
Sweeney's trial was marred by a “combination of extraordi-
nary failures from juror to judge to attorney” that deprived
Sweeney of his right to be confronted with the witnesses
against him and his right to trial by an impartial jury. App.
to Pet. for Cert. 22a, 29a. That error, the Court of Appeals
concluded, entitled Sweeney to a new trial. Judge Quattle-
baum dissented, criticizing the majority for “fout[ing]” tradi-
tional principles of party presentation. Id., at 99a–103a.
II
“In our adversarial system of adjudication, we follow the
principle of party presentation.” United States v. Sineneng-
Smith, 590 U. S. 371, 375 (2020). The parties “ `frame the
issues for decision,' ” while the court serves as “ `neutral arbi-
ter of matters the parties present.' ” Ibid. (quoting Green-
law v. United States, 554 U. S. 237, 243 (2008)). To put it
plainly, courts “call balls and strikes”; they don't get a turn
at bat. Lomax v. Ortiz-Marquez, 590 U. S. 595, 599 (2020).
The Fourth Circuit transgressed the party-presentation
principle by granting relief on a claim that Sweeney never
asserted and that the State never had the chance to address.
Sweeney asserted “one, and only one,” claim in his federal
habeas petition: that his counsel was ineffective for failing to
investigate whether other jurors had been prejudiced by
Juror 4's crime-scene visit. App. to Pet. for Cert. 53a (Quat-
tlebaum, J., dissenting). Instead of ruling on that claim, the
Fourth Circuit devised a new one, based on a “combination
of extraordinary failures from juror to judge to attorney.”
Page Proof Pending Publication

Page Proof Pending Publication
10 CLARK
v. SWEENEY
Per Curiam
Id., at 22a. The Fourth Circuit's “radical transformation” of
Sweeney'
s simple ineffective-assistance claim “departed so
drastically from the principle of party presentation as to con-
stitute an abuse of discretion.” Sineneng-Smith, 590 U. S.,
at 380, 375. We accordingly reverse the judgment of the
Fourth Circuit and remand the case for further proceedings.
On remand, the Four th Circuit shou ld ana lyze the
ineffective-assistance claim that Sweeney asserted. Under
the Antiterrorism and Effective Death Penalty Act of 1996,
relief is barred unless the state court's decision was “con-
trary to, or involved an unreasonable application of, clearly
established Federal law, as determined by the Supreme
Court of the United States.” 28 U. S. C. § 2254(d). When
assessing a Strickland claim that a state court has already
adjudicated, the “analysis is `doubly deferential.' ” Dunn v.
Reeves, 594 U. S. 731, 739 (2021) (per curiam) (quoting Burt
v. Titlow, 571 U. S. 12, 15 (2013)). “[A] federal court may
grant relief only if every `fairminded jurist' would agree that
every reasonable lawyer would have made a different deci-
sion.” 594 U. S., at 739–740 (quoting Harrington v. Richter,
562 U. S. 86, 101 (2011)).
The petition for certiorari is granted, the judgment of the
Fourth Circuit is reversed, and the case is remanded for fur-
ther proceedings consistent with this opinion.
It is so ordered.

Page Proof Pending Publication
Reporter’s Note
The attached opinion has been revised to refect the usual publication
and citation style of the United States Reports. The revised pagination
makes available the offcial United States Reports citation in advance of
publication. The syllabus has been prepared by the Reporter of Decisions
for the convenience of the reader and constitutes no part of the opinion of
the Court. Other revisions may include adjustments to formatting, cap-
tions, citation form, and any errant punctuation. The following additional
edits were made:
p. 7, line after the case name: “on petition for writ of” is inserted
before “certiorari”